Version 1.1 | Dated: 22 November 2021
This policy applies to the following businesses:
ISS Group Holdings Ltd, Registered Company number 03650395 Registered Office 8th Floor, 60 Fenchurch Street, London, England, EC3M 4AD
- GLOSSARY OF TERMS
- WHAT INFORMATION DO WE COLLECT ABOUT YOU AND HOW?
- HOW WILL WE USE THE INFORMATION ABOUT YOU AND WHY?
- TRANSFERRING YOUR INFORMATION OUTSIDE OF EUROPE
- SECURITY PRECAUTIONS IN PLACE ABOUT DATA COLLECTED
- HOW LONG WILL WE HOLD YOUR DATA FOR?
- ACCESS TO YOUR INFORMATION, CORRECTION, PORTABILITY AND DELETION
- OTHER WEBSITES
- HOW TO CONTACT US
- ADDITIONAL INFORMATION
GLOSSARY OF TERMS
What is personal data?
Personal data relates to any information about a natural person that makes you identifiable which may include (but is not limited to):
- Names and contact information ie emails and telephone numbers
- National Insurance Numbers
- Employment history
- Employee numbers
- Credit History
- Personal tax
- Payroll and accounting data
What is sensitive personal data?
Sensitive personal data refers to the above but includes genetic data and biometric data.
- Medical conditions
- Religious or philosophical beliefs and political opinions
- Racial or ethnic origin
- Biometric data (eg photo in an electronic passport)
What is a Data Controller?
For general data protection regulation purposes, the “data controller” means the person or organisation who decides the purposes for which and the way in which any personal data is processed.
The data controller is ISS Group Holdings Ltd, 8th Floor, 60 Fenchurch Street, London, England, EC3M 4AD.
The data protection officer is Giles Stanley, Head of Legal Service who can be contacted at the above address or on DATA.PROTECTION@ISS-SHIPPING.COM or by calling 01375 484900.
What is a Data Processor?
A “data processor” is a person or organisation which processes personal data for the controller.
What is Data Processing?
Data processing is any operation or set of operations performed upon personal data, or sets of it, be it by automated systems or not. Examples of data processing explicitly listed in the text of the GDPR are: collection, recording, organising, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, aligning or combining, restricting, erasure or destruction.
What do we mean by Business to Business?
PLC, LTD, LLP incorporated partnerships, trusts and foundations, local authorities and government institutions.
What do we mean by Business to Consumer?
Private clients, sole traders, unincorporated partnerships, trusts and foundations.
WHAT INFORMATION DO WE COLLECT ABOUT YOU AND HOW?
Inchcape Shipping Services, as a Data Controller, is bound by the requirements of the General Data Protection Regulations (GDPR) and the rules of the countries we operate in, for example the South African Protection of Personal Information Act, 4 of 2013.
You agree that we are entitled to obtain, use and process the information you provide to us to enable us to discharge the Services (as defined in our Contracts)and for other related purposes including;
- Updating and enhancing client records
- Analysis for management purposes
- Carrying out credit checks in relation to you
- Statutory returns
- Legal and regulatory compliance
- Crime prevention
We collect information about you when you fill in any of the forms on our websites i.e. sending an enquiry, signing up for an event, filling in a survey, giving feedback, applying for a vacancy, etc. Where necessary, website usage information is collected using cookies.
Cookies are text files put on your computer to collect standard internet log information and visitor behaviour information. This information is then used to track visitor use of the website and to create statistical reports on website activity. For more information visit WWW.ABOUTCOOKIES.ORG or WWW.ALLABOUTCOOKIES.ORG.
You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. Please note in a few cases some of our website features may not function because of this.
Analytics – e.g. how visitors use our website
We use Google Analytics to store information about how visitors use our website so that we may make improvements and give visitors a better user experience.
Google – HTTP://WWW.GOOGLE.COM/INTL/EN/POLICIES/PRIVACY/
An IP or Internet Protocol Address is a unique numerical address assigned to a computer as it logs on to the internet. Inchcape Shipping Services do not have access to any personal identifiable information and we would never seek this information. Your IP address is logged when visiting our site, but our analytic software only uses this information to track how many visitors we have from particular regions.
Internet Based Advertising
We use Linkedin, Instagram, Facebook and Twitter advertising services and as such there are tracking codes installed on our website so that we can manage the effectiveness of these campaigns. We do not store any personal data within this type of tracking.
HOW WILL WE USE THE INFORMATION ABOUT YOU AND WHY?
At Inchcape Shipping Services we take your privacy seriously and will only use your personal information to provide the Services you have requested from us, detailed in your Contract Schedules and as we have identified above. We will only use this information subject to your instructions, data protection law and our duty of confidentiality.
For Business to Business Clients and Contacts our lawful reason for processing your personal information will be “legitimate interests”. Under “legitimate interests” we can process your personal information if: we have a genuine and legitimate reason and we are not harming any of your rights and interests.
For Business to Consumer Clients and Contacts our lawful reason for processing your personal information will be “A contract with the individual” e.g. to supply goods and services you have requested, or to fulfil obligations under an employment contract. This also includes steps taken at your request before entering into a contract. As part of engaging in a contract, additional personal data may be required for the purpose of legal and regulatory compliance.
Our work for you may require us to pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing the Services to you on our behalf. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the Services and we have contracts in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.
We collect information on our website to process any enquiries. If you agree, we will also use this information to share updates with you about our services which we believe may be of interest to you.
We will not share your information for marketing purposes with companies so that they may offer you their products and services.
TRANSFERRING YOUR INFORMATION OUTSIDE OF EUROPE
As part of the services offered to you through this website, the information which you give to us may be transferred to countries outside the European Union (“EU”). For example, some of our third-party providers may be located outside of the EU. Where this is the case we will take steps to make sure the right security measures are taken so that your privacy rights continue to be protected as outlined in this policy.
By submitting your personal data, you’re agreeing to this transfer, storing or processing. Where our third-party supplies are in the US we have ensured that their services fall under the “PRIVACY SHIELD” whereby participating companies are deemed to have adequate protection and therefore facilitate the transfer of information from the EU to the US.
If you use our services while you are outside the EU, your information may be transferred outside the EU to give you those services.
SECURITY PRECAUTIONS IN PLACE ABOUT DATA COLLECTED
When you give us personal information, we take steps to make sure that it’s treated securely. Any sensitive information (such as credit or debit card details) is encrypted. When you are on a secure page, a lock icon will appear on the bottom of web browsers such as Microsoft Internet Explorer.
Non-sensitive details (your email address etc.) are sent normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
We would like to send you information about our services which may be of interest to you. If you have consented to receive marketing, you may opt out at any point as set out below. You may also receive marketing due to being under a contract which includes marketing and information updates.
You have a right at any time to stop us from contacting you for marketing purposes. To opt out please email email@example.com
We process personal information relating to individuals who apply to work at Inchcape Shipping Services in order to carry out the initial screening processes. Information collected through our website include the applicants name, contact details, nationality, previous work history, etc. The personal data collected is exclusively processed for the purposes of identifying suitable candidates to be considered for hiring.
If there are no suitable vacancies, an applicant is permitted to upload their CV to be stored in our database for the period of six months and will thereafter be deleted. In the event that a vacancy becomes available within the six months of uploading, Inchcape Human Resources will review the CV database for suitable applicants to contact for interviews.
You have a right at any time to request to be removed from our database. To opt out please email
HOW LONG WILL WE HOLD YOUR DATA FOR?
Marketing: We will hold your data until you tell us to not hold said data. You will have the opportunity to opt out or update or delete data at any point should you need to do so and details are set out in this policy as to how to do that.
Contracted Services: We will hold your data for the life of the contract, as per any contracted terms and in line with our regulatory requirements whichever is greater.
Recruitment: We will hold your data for the period of six months, thereafter your application and CV will be deleted.
ACCESS TO YOUR INFORMATION, CORRECTION, PORTABILITY AND DELETION
What is a Subject Access Request?
This is your right to request a copy of the information that we hold about you. If you would like a copy of some or all your personal information, please email DATA.PROTECTION@ISS-SHIPPING.COM
We will respond to your request within one month of receipt of the request.
We want to make sure your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate by emailing DATA.PROTECTION@ISS-SHIPPING.COM or writing to the above address.
Objections to processing of personal data
It is your right to lodge an objection to the processing of your personal data if you feel the “ground relating to your particular situation” apply. The only reasons we will be able to deny your request is if we can show compelling legitimate grounds for the processing, which override your interest, rights and freedoms, or the processing is for the establishment, exercise or defence of a legal claims.
It is also your right to receive the personal data which you have given to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without delay from the current controller if:
(a) The processing is based on consent or on a contract, and
(b) The processing is carried out by automated means.
Your Right to be Forgotten
Should you wish for us to completely delete all information that we hold about you then email this request to DATA.PROTECTION@ISS-SHIPPING.COM
If you feel that your personal data has been processed in a way that does not meet the GDPR, you have a specific right to lodge a complaint with the relevant supervisory authority. The supervisory authority will then tell you of the progress and outcome of your complaint. The supervisory authority in the UK is the INFORMATION COMMISSIONER’S OFFICE.
HOW TO CONTACT US
Protection of Personal Information Act, 4 of 2013 – Any additional information or concerns can be found and raised with the Information Regulator, who can be contacted as shared below, but please feel free to contact us first to discuss any questions or concerns you may have:
Tel: +27 012 406 4818